Transcript Slide 1

SME Supply Chain
Management
What’s important to being &
staying competitive?
Robert Krieger
President
What is a Customs Broker?
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Licensed by CBP
Part of the Dept. of Homeland Security
Corporate License & Permit
Individual License Holders
What is import when choosing one
What is an International Freight
Forwarder?
• Licensed by FMC
• NVOCC tariffs
published
• Anti-rebate policy
• Confusing
terminology
• Not licensed
• Most CNS (IATA)
members
• TSA regulation
US Focus on Security
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National Threat Center
Increased examinations
Voluntary C-TPAT program
Stepped up TSA enforcement
Krieger Worldwide
• Customs Brokerage & Forwarding in USA,
Mexico and Hong Kong
• Warehouse & Distribution Services
• Domestic Transportation
• Logistics Consulting Services
• Insurance
• Duty Drawback programs
• Importer Security Filings
What do you need to know?
Concerns
Opportunities
Customs Regulations
• Regulated by 19CFR
– “Informed Compliance & Reasonable Care”
– Importers required to submit Entry
• Most importers use brokers
• Entries filed electronically
– Includes data about manufacturer, importer,
classification, conveyance, and valuation
Importers Responsibility
• Verify accuracy of entry
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Prior to submission
Marking of Goods
Description
Country of Origin
Manufacturer
Piece Count
Entry Review
• Government retains right to review entry
– Review final upon liquidation
• Importer retains right to review entry
– Strict time limitations apply
Examination
• Government retains right to inspect cargo
– Based on entry criteria
– Based on risk management
– Depending on product & statutes up to 6 months
after importation
• Failure to redeliver results in penalty
• Regardless of examination importer
responsible to be comply
Non-Compliance
• If CBP believes importer in violation
– Likely investigation
– Possible civil penalties
– Possible criminal penalties
Related Party
• Most brokers don’t ask
• Most importers answer incorrectly when
asked
• Significance?
Valuation
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Transaction value is implied (TV)
TV of identical merchandise
TV of similar merchandise
Deductive value
Computed value
Sec 152.107 value if other values cannot be
determined
Transaction Value
• Additions to arrive at dutiable value
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Royalties
Licensing fees
Packing costs
Selling commissions
Apportioned value of any assists
• Penalties for omissions & wrong valuation
Classification
• How to determine correct rate of duty?
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Harmonized Tariff over 215,000 classifications
Modified by chapter notes
Modified by GRI’s
Effected by Binding Rulings
Effected by court decisions
Examples
• Wheel Chairs
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Custom’s view
Importer’s view
Our view
Verdict
• Radio Watches
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Custom’s view
Importer’s view
Our view
Verdict
Freight Issues
• When can we get the freight?
• How much will it cost? What is the real cost?
• Individual shipment bids—wasteful
• Tendency to focus on lowest bidder
• What is the real cost of cheap rates & poor
service to your business?
Case Study in Freight
• Audited 36 random transactions
– Poor carrier selection
• Vessels too slow (China-DC = 26-31 days)
• Unreliable service
• Over dependence on airfreight when speed needed
– Airfreight issues
• Dimension on AWB 12% above packing list
• Transit time, factory to door, 12 days!
Findings in the Case Study
• Problems identified:
– Customs broker different from Forwarder
• Did not coordinate well together
– Customs broker coordinated poorly with trucker
– Forwarder used cheapest airline, charged
premium rates and overcharged on dimension
Additional Findings
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Freight shipped to wrong port
Paid freight on CFR shipments
Paid insurance twice
Did not consolidate freight
Paid extremely high export freight rates
Visit to Distribution Center
• Measured 40 different cartons
– Most had incorrect measurements printed
on the cartons
Case Study Conclusion
$2,000,000.00 to $3,000,000.00
Possible savings if international freight properly
managed.
Export Issues
• Duty Drawback
– Goods imported then re-exported
– Fungible items
– Complex—may not be worth the effort
• Export Controls
– Controversial
– Difficult to understand
Hot Topics
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Import Compliance
Free-Trade Agreements
Foreign Trade Zones (FTZ)
Security
Import Compliance
• Focused Assessments
• Increased Audits
• Smuggling & Illegal Transshipments
– Importers must take steps to verify origin
– Detentions & seizures have increased
FTZ – Free Trade Zone
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Goods outside Customs Territory of US
Tariff shifts possible
Delays duty payment
Export without drawback headaches
Fix problematic goods
Reduce MPF
Conclusion
• Importing is extremely complex
– Regulated by Customs & other agencies
– Easy to make mistakes
– Importer needs to be compliant
• Importer’s best friend = Broker/Forwarder
Thank You